We also recommend that the standards apply to existing as well as new development, to publicly-owned 1 as well as private property. For example, there should be a commitment by government agencies to apply 2 the standards to manage stormwater runoff whenever public infrastructure undergoes significant 3 maintenance, repair or replacement, or when private development is substantially improved or 4 redeveloped. State agencies and regional governments should also set an example by using green 5 infrastructure in their construction and maintenance activities, to help build awareness and experience 6 with these practices. Green infrastructure retrofits are already part of the Illinois MS4 program. The 7 state should develop guidance to ensure that green infrastructure practices are used appropriately to work 8 most effectively in reducing pollution, erosion and sedimentation, and flood risks, while providing the 9 ancillary benefits of improved habitat and aquifer recharge opportunities. 10
FUNDING GREEN INFRASTRUCTURE 11
Setting aside 20% of the Clean Water State Revolving Fund for a Green Project Reserve has not had any 12 serious impact on IEPA’s ability to fund traditional projects to date. We believe that in the future, with 13 more municipalities applying for green project funding, there will be an increased interest and need for 14 funding such projects and this need may very well exceed 20% of the annual fund. We further believe 15 that the IEPA SRF allocation policy should recognize the enormous adverse impact of unregulated 16 stormwater discharges on the water quality of state waters, and that the funding of stand-alone stormwater 17 projects should have a much higher priority in the future relative to the funding of traditional wastewater 18 projects. Assuming that IEPA takes this approach, there should be no negative consequences from a 19 long-term policy of setting aside 20% of the SRF for a Green Project Reserve. 20
We also recommend that IEPA substantially increase prioritization of applications for funding the more 21 sustainable traditional projects, as this will further enhance the effectiveness of IEPA funding 22 investments. Increasing the sustainability or efficiency of all projects should reduce the need for yet more 23 funding in the future, as systems are put in place that last longer and require less maintenance, repair and 24 replacement. This is not so much an issue of being more “green” as it is developing a wiser investment 25 strategy. 26
The Fiscal Year 2010 federal appropriation bill passed in October 2009 provided another round of 28 exceptionally large water infrastructure grants to states and repeated the mandates for green infrastructure 29 projects and grants contained in the American Recovery and Reinvestment Act of 2009 (ARRA). It is 30 also our understanding from discussions with the U.S. Environmental Protection Agency that the current 31 draft language in the Fiscal Year 2011 federal appropriation bill shows Congress’ intent to continue these 32 two requirements for the foreseeable future in its annual appropriations. However, to make best use of 33 these federal funds, Illinois EPA must adopt a clear prioritization system to determine which of the 34 municipal green infrastructure projects should receive funding first under its earmarked Green Project 35 Reserve funds. This system should be designed to encourage applications for a wide variety of green 36 infrastructure project all over the state. 37
Unlike the limited interest shown by local governments in Illinois in using ARRA’s Green Project 39 Reserve to support green infrastructure practices for urban stormwater management, states with strong 40 education and outreach programs have received many applications for green infrastructure projects and 41 have given out millions of dollars in grants for green infrastructure project costs. We conclude that 42
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